financial disclosure management (fdm) system … 1 financial disclosure management (fdm) system...

https://www.fdm.army.mil1

Financial Disclosure Management (FDM)

SystemOverview

FDM Program Management OfficeArmy Office of the General Counsel

Ethics & Fiscal

[email protected]

November 2019

Presenter

Presentation Notes

Purposes: Describe how DoD ethics officials use the Army's secure, online Financial Disclosure Management (FDM) system to electronically manage and review the OGE 278, Public Financial Disclosure Report, and the OGE 450, Confidential Financial Disclosure Report. Cover select topics on FDM use including: migration to online eFiling/eReviewing, and filing season preparations. FDM History (very brief) The Financial Disclosure Management (FDM) software program helps Filers accurately prepare and electronically file a Financial Disclosure Report (either the 278, Public Financial Disclosure Report, or the Office of Government Ethics (OGE) Form 450, Confidential Financial Disclosure Report). FDM is a secure, online application that simplifies financial disclosure report preparation and review saving time and eliminating common errors. Although centrally overseen, FDM works for local legal advisors.


OGE 278s – Transition to Integrity

• Effective January 1, 2020, all DoD OGE 278s will be filed using OGE’s Integrity filing system.

• The only OGE 278s filed in FDM after that date will be Termination or Combination reports due prior to August 13, 2020.

• OGE 450 Confidential Financial Disclosure Reports will continue to be filed in FDM.

Presenter

Presentation Notes

Slide lists the Key FDM 278 roles. Earlier I mentioned that FDM is role-based. A user must be registered with a particular role to use FDM. The role determines what a user may do and see in FDM. For example, a Filer may create a report but not see other Filers in FDM. A Senior Legal Counsel, or SLC, is usually the legal advisor to a 278 Filer. The SLC may review that filer’s report. The DAEO or DDAEO may certify a Filer’s report for filers within the DAEO’s AOR (in FDM “span of control”).


• Office of Government Ethics (OGE) approved, secure, web-based application that improves the financial disclosure report preparation, filing, review, and tracking process

• Paperless report and online review using eSignatures• Works similar to income tax filing software:

– Guides filer through questions about reportable financial information

– Flags missing and incorrect information– Starts each report with prior report information –

“prepopulation”

FDM is…


FDM Provides…

Centralized administration & monitoring with tools to:– Remind & notify filers, supervisors, and POCs– Permit initial screening/reviews and comments by

supervisors and support staff– Compare current report data to prior report for

reconciliation– Upload supporting documents & guidance– Run management reports & export data to Excel– Extract data for OGE Annual Agency Questionnaire– Track annual ethics training– Purge at record retention expiration

Presenter

Presentation Notes

Ask yourself what is in it for me?


Benefits

Only a filer and his/her review chain can see the report. All information is protected through the use of security features such as SSL 128-bit encryption and user authentication.

Efficient

Accurate

Secure

Report wizard leads users through the report form filling and review process. FDM’s paperless workflow eliminates the physical hand-offs between filers and reviewers. Existing filers “pre-populate” reports from earlier ones. Reviewers have a report “Compare” function for repeat filers (2 reports in FDM).

Incorporates Office of Government Ethics (OGE) business rules ensuring accurate and consistent reports. Reduces common errors.

Convenient access via InternetAccess

. . . to assist reviewers get to Conflict of Interest analysis

Presenter

Presentation Notes

FDM is a software tool for electronic filing and processing of OGE 450s. Named an OGE Agency Model Practice in 2009, here you see a summary of key benefits of using FDM, our software tool to assist reviewers get to the Conflict of Interest analysis: Bottom line is that FDM should assist reviewers get to Conflict of Interest analysis Per Kerri Cox, formerly AF OGC’s FDM POC: It saves a tremendous amount of time and money on the part of the filer and the attorneys for the following reasons: 1. All filers forms are stored in the system. This means that agencies no longer have to fax, scan and email, or FedEx forms back and forth to filers or lawyers saving time and money. (This would be particularly helpful for an agency like DIA that has so many filers from other agencies.) 2. The pre-populate feature creates a draft lessening the time the filers spend on inputting information. 3. Because the forms are stored in the system and there is a pre-populate button there are many less mistakes making reviewing time shorter. (This is particularly helpful with the complicated forms of PAS and others with significant assets.) 4. There is a compare feature which does an electronic comparison of last year's form to this lessening review time even further. 5. All documents related to the 278 can be stored in the system: position descriptions, cautionary letters, etc. 6. The system will track (I forget whether this feature is up and running or coming in next upgrade) all the numbers for the annual OGE agency ethics report. I have stacks of comments from filers last year who all said the system was easy to use. This year is the first year AF filers are using the pre-populate feature and I am already getting comments from filers that they love the pre-populate feature, that it was the easiest year yet to file.


Understanding FDM

• Roles based – a user has one or more “roles” that determine what that user may do/see in FDM depending on the role selected

• Process Flows – Reports have an assigned process flow for data input and review

• Org Units – Ethics offices & POCs establish and structure “org units” in FDM and assign user roles for each org unit. Roles flow down to subordinate org units unless the role is assigned to another user at the subordinate org unit level.

Presenter

Presentation Notes

Now, let’s look at a few key fundamentals to understand FDM: It is Role based so access is limited to registered users who have one or more “roles” that determine what that user may do and/or see in FDM. To get registered check with your GC/SJA or Supervisor. FDM has work flow rules in place for the OGE 278/OGE 450 FDM has a Structure that “connects” filers & reviewers to limit who may see a particular report FDM uses an “org unit” concept to connect filers, reviewer/supervisors, legal community users, & report certifiers


Key FDM User Roles• DAEO/DAEO EC – OGE 278 certifying authority.* A DAEO

may have multiple DAEO ECs. Note this is the “FDM DAEO” not necessarily the legal agency “DAEO”

• 450 Certifier/EC – OGE 450 certifying authority. A Certifier may have multiple ECs.– 450 Assistant – assists Certifier in managing process/initial reviews.

• SLC/SLC EC – Senior Legal Counsel. Primarily serves to identify ethics counsel at subordinate legal offices who may have initial review and annual reporting responsibilities.– SLC Assistant – Assists SLC/SLC EC to manage process

* Note – The DAEO role(s) will remain, however, effective January 1, 2020, OGE 278 filing will migrate to OGE’s Integrity filing system.


Key FDM User Roles• POC – organization point of contact (POC) for managing filing

and org unit structure in FDM. Tracks and notifies ethics counsel regarding incoming/departing filers and supervisors. Ideally should be individual responsible for in/out processing in that organization.

• Supervisor – Filer’s Supervisor. Need not be immediate/rater, just in chain of command. Use of 1st tier supervisors may create overly complex org structure, so 2nd or 3rd tier may be desirable

• Filer – Self-explanatory– Filer Assistant – optional; usually someone on filer’s

administrative support staff. May draft Filer’s report; cannot eSign for Filer; cannot amend for Filer

Presenter

Presentation Notes

Slide lists the Key FDM 278 roles. Earlier I mentioned that FDM is role-based. A user must be registered with a particular role to use FDM. The role determines what a user may do and see in FDM. For example, a Filer may create a report but not see other Filers in FDM. A Senior Legal Counsel, or SLC, is usually the legal advisor to a 278 Filer. The SLC may review that filer’s report. The DAEO or DDAEO may certify a Filer’s report for filers within the DAEO’s AOR (in FDM “span of control”).


Adding Users• FDM identifies users by reference to the DISA Global Directory

Service (GDS), https://dod411.gds.disa.mil/• When adding or moving a user, FDM queries GDS and you select the

user from the resultant list– If GDS has not been updated, FDM/GDS may identify the user by an old e-mail

address (e.g., osd.mil or army.mil). Verify this is the correct person, just an old e-mail address, and then have the user login and update their e-mail address in FDM. Only the user can change their FDM e-mail address.

– You may need to request the user send you a digitally signed e-mail to identify what e-mail address is associated with the user’s CAC.

Presenter

Presentation Notes

Avoid a Privacy Act violation -- assign the correct Supervisor by using the e-mail address embedded on that person's Common Access Card (CAC). A basic FDM search using only first and last name may return many individuals with the same or similar names and you could inadvertently select the wrong person which could allow an unauthorized access to a filer's report and violate a Filer's privacy. If you are unsure who to select from the search results contact the person you are trying to register to verify the email address embedded on their CAC. You could also search on the Defense Information System Agency Global Directory Service, https://dod411.gds.disa.mil/.

https://dod411.gds.disa.mil/


FDM Web Site – Home https://www.fdm.army.mil

Presenter

Presentation Notes

You are probably already familiar with the FDM home page shown here; login to FDM feature. Tabs to navigate to different areas. Notice the Information for . . . area on the left. Content is tailored to the specific role and FDM use. There is a link for a 4 minute, narrated tour of the FDM web site.

https://www.fdm.army.mil/


FDM Web Site Resources

Presenter

Presentation Notes

This slide shows the FDM Help & Support | Resources sub tab displaying the various resources arranged topically by General, OGE 278, and OGE 450. You will need to scroll to see the OGE 450 resources.


Report TabsClick to display the first page for the tab and any tab menu items

Menu TabsClick to display

InstructionsProvide directions on how to enter data

User Profile

Common QuestionsClick to display

Progress BarUse to move to different report section

Navigating FDM

Presenter

Presentation Notes

After completing Contact Information page, FDM user gets more tabs and features based on the user’s role(s). Here you see Filer oriented navigational items to move between report sections and features and in a particular report section as shown here. Each page has a title. Each role has Tabs based on that user’s role(s). Here you see those standard for a filer, My Reports, My Info, Resources. SLCs and Supervisors have Review Filers and Admin tabs (between My Info and Resources). The report progress bar lets the user move through the report by section (corresponds to the 278 schedules). Common Questions are links to answers intended to assist the user and are tailored to that particular section of the report.

https://www.fdm.army.mil

Key Features - Filers

• Filers can prepare the report themselves or add an assistant who can draft it

• A report Q&A “wizard” & progress bar guides the Filer through with questions and tailored help

• Pre-population simplifies the filing: – Filers carry forward previous report data to their next reports – edit changes

• FDM flags incomplete items• Filer eSigns the report securely online• eMail notifications go to reviewers when Filer eSigns or

amends

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https://www.fdm.army.mil

Key Features - Reviewers(Supervisors and Ethics Counselors)

• e-Mail notices alert reviewers of report review readiness status

• Worklist view shows reports ready for review & tracks in-progress reports

• OGE reporting business rules applied to flagging issues requiring additional information or special attention

• Reviewers can add comments directly to a report• Reviewer eSigns report securely online• Audit trail records report status changes• Compare view shows changes Filers make between

reports saving Reviewers report reconciliation time

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Ethics Training

• Legal official roles may notify Filers & record Ethics Training for Filers

• Tabs:• Not Trained• Trained• Exceptions

• Use is optional; info in FDM will be available for SLC input to annual Agency report to OGE

• Print each year’s Training Record BEFORE 31 Dec of that year!

• Ethics Training | Trained• Ethics Training | Not Trained

Quick Reference: https://www.fdm.army.mil/documents/QRC_Manage_Ethics_Training.pdf

Presenter

Presentation Notes

We added a tab for managing Ethics Training records for your supported filers. The Quick Reference explains it. Here you can see your untrained filers, notify them of the training, then when training is complete, record that for later retrieval (the annual ethics report).

https://www.fdm.army.mil/documents/QRC_Manage_Ethics_Training.pdf

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